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HomeMy WebLinkAbout14-1488s E C T I 0 N A s E C T I 0 N B Supreme Court of Pennsylvania Cumberland County For Prothonotary Use Only: �r Docket No: / _ / (( /4ir The information collected on this form is used solely for court administration pzrrposes. This form does not sunplenzent or replace the Jiling and service oft)leadings or other papers as required by law or rules of court. Commencement of Action: Petition ❑ Notice of Appeal Declaration of Taking © Complaint ❑ Writ of Summons ❑ ❑ Transfer from Another Jurisdiction ❑ Lead Plaintiffs Name: Carlyn Butz Lead Defendant's Name: Thomas B. Divver and CAPITAL MEATS, INC. ❑ Check here if you are a Self-Represented (Pro Se) Litigant Name of Plaintiff /Appellant's Attorney: George B. Faller, Jr., Esquire Dollar Amount Requested: XX within arbitration limits Are money damages requested? : Yes ❑ No (Check one) outside arbitration limits Is this a Class Action Suit? ❑ Yes © No Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) ❑ Intentional ❑ Malicious Prosecution Motor Vehicle ❑ Nuisance ❑ Premises Liability ❑ Product Liability (does not include mass tort) ❑ Slander/Libel/ Defamation ❑ Other: MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant ❑ Toxic Waste ❑ Other: PROFESSIONAL LIABLITY ❑ Dental ❑ Legal ❑ Medical ❑ Other Professional: Pa.R.C.P. 205.5 CONTRACT (do not include Judgments) ❑ Buyer Plaintiff ❑ Debt Collection: Credit Card ❑ Debt Collection: Other ❑ Employment Dispute: Discrimination ❑ Employment Dispute: Other ❑ Other: REAL PROPERTY ❑ Ejectment ❑ Eminent Domain /Condemnation ❑ Ground Rent ❑ Landlord /Tenant Dispute ❑ Mortgage Foreclosure ❑ Partition ❑ Quiet Title ❑ Other: CIVIL APPEALS Administrative Agencies ❑ Board of Assessment ❑ Board of Elections ❑ Dept. of Transportation ❑ Zoning Board ❑ Statutory Appeal: Other Judicial Appeals ❑ MDJ - Landlord /Tenant ❑ MDJ - Money Judgment ❑ Other: MISCELLANEOUS ❑ Common Law /Statutory Arbitration ❑ Declaratory Judgment ❑ Mandamus ❑ Non- Domestic Relations Restraining Order ❑ Quo Warranto ❑ Replevin ❑ Other: 2/2010 FAFILES \Clients \3050 Donegal\3050 Currentl3050.711 \3050.711.complaintl.wpd .44 Revised: 3/13/14 10:27AM George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs t'ILD-OFF- THE PRO 1110NOTAW: 2014MAR I 3 FM 3: I 1 CUMBERLAND COUNTY PENNSYLVANIA CARLYN BUTZ, Plaintiff v. THOMAS B. DIVVER and CAPITAL MEATS, INC., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, ENNSYLVANIA NO. /f.-1/4(6174? 41, I : CIVIL ACTION - LAW : JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 4/03.75? ods- P 30.2q3 •-• George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs CARLYN BUTZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. : CIVIL ACTION - LAW THOMAS B. DIVVER and CAPITAL MEATS, INC., Defendant : JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff Carlyn Butz is an adult individual residing at 1784 Winterhaven Drive, Mechanicsburg, Pennsylvania 17055 2. Defendant Thomas B. Divver is an adult individual residing at 166 Airport Drive, Suite 1, Westminster, Maryland 21157. 3. The Defendant Capital Meats, Inc., is a Virginia business entity with an address at P.O. Box 1210 Stephens City, VA 22655-1210. 4. Plaintiff was the owner of a 2013 Toyota Corolla. 5. On or about June 10, 2013, Plaintiffs stepdaughter, Meredith Butz, was operating her 2013 Toyota Corolla traveling north on the Gettysburg Pike, Upper Allen Township, Cumberland County, Pennsylvania. 6. At that time, a vehicle owned by the Defendant Capital Meats, Inc., and operated by Defendant Thomas Divver was in a driveway at 347 Gettysburg Pike. 7. As the Plaintiffs vehicle was approaching the driveway, the Defendant Divver pulled out directly in front of the Plaintiff s vehicle, thereby causing a crash between the two. 8. The crash was caused solely as a result of the negligence, recklessness, and carelessness of the Defendants. 9. As a direct and proximate result of the crash, the Plaintiffs vehicle which had a fair market value of $17,299.20 was totaled. The vehicle, however, did have a salvage value of $4,161.00 for a net loss to the Plaintiff of $13,138.20. COUNT I Carlyn Butz v. Thomas B. Divver 10. The averments of paragraphs 1 through 9 are hereby incorporated by reference. 11. The collision was caused solely as result of the negligence, recklessness and carelessness of the Defendant Divver in that he: a. failed to yield the right-of-way; b. failed to properly look to ascertain that it was safe to enter Gettysburg Pike before pulling out on to the roadway; c. operating his vehicle in violation of Section 3714 of the Pennsylvania Motor Vehicle Code; and d. failing to operate his vehicle in a manner to avoid it causing the collision with Plaintiff's vehicle; WHEREFORE, Plaintiff demands judgment against the Defendant Thomas B. Divver in the amount of $13,138.20, plus interest and costs. COUNT II Carlyn Butz v. Capital Meats, Inc. 12. The averments of paragraphs 1 through 11 are hereby incorporated by reference. 13. At the time ofthe collision, the Defendant Divver was operating the vehicle as an agent, servant, or employee of the Defendant Capital Meats, Inc., and with their express or implied permission to do so. WHEREFORE, Plaintiff demands judgment against the Defendant Capital Meats, Inc., in the amount of $13,138.20, plus interest and costs. MARTSPA LAW OFFIC 5 George er, Jr., Esquir I.D. Num r 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: 3/13/14 Attorneys for Plaintiff VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. FAFILESTlients \ 3050 Donegal\3050 Current \ 3050.711 \3050.711.complaintl,wpd F:\FILES \Clients \3050 Donegal\3050 Current\3050.711\3050.71 I affl.wpd Revised: 3/21/14 1 1:33 AM George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243 -3341 Attorneys for Plaintiffs 25 PH I :3 PENNSYLVANIA CARLYN BUTZ, Plaintiff v. THOMAS B. DIVVER and CAPITAL MEATS, INC., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14 -1488 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE OF COMPLAINT COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND I hereby certify that a copy of the Complaint in the above captioned matter was mailed to Capital Meats, Inc., at P.O. Box 1210, Stephens City, VA 22655 -1210, by certified mail. Attached is the Post Office return receipt signed and dated March 17, 2014. MARTSON LAW OFFICES By George B. Faller, Jr., Esquire Attorney ID No. 49813 Ten East High Street Carlisle, PA 17013 (717) 243 -3341 Sworn to and subscribed before me this o1Li +'Pi day of m412CH , 2014. Notar ' ublic COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Dena S. Brumbaugh, Notary Public Carlisle Boro, Cumberland County My Commission Expires Feb. 18, 2018 MEMBER. PENNSYLVANIA ASSOCIATION OF NOTARIES SENDER: COMPLETE THIS SECTION • Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ■ Print your name and address on the reverse so that we can return the card to you. • Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Co 4-r i' P.D. Pax a ■D Sit vns Cu. 4 2..,-tps5'(atc COMPLETE THIS SECTION ON DELIVERY A. Signature X rd' B. Received by ( Print ! Name) ❑ Agent ❑ Addressee C. Date of Delivery D. Is delivery address • ifferent from item 1? ❑ Yes If YES, enter delivery address below: ❑ No 3. Se Ice Type Certified Mail ❑ egistered ❑ Insured Mail ❑ Express Mail ❑ Return Receipt for Merchandise ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) 2. Article Number (Transfer from service label) Yes 7009 2820 0002 2103 7410 PS Form 3811, February 2004 Domestic Return Receipt 102595 -02 -M -1540 I F:\FILES\Clients\3050 Donegal\3050 Current33050.71 l\3050.71 I .pral.wpd/ajt Created: 7/10/03 10:28 AM Revised: 5/15/14 9:09AM George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff r.IL LD -UI {,..f,.,,,. it THE PROTHONOTARY 23I'EfiY 15 A1110: 27 CUMBERLAND COUNTY PENNSYLVANIA CARLYN BUTZ, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-1488 : CIVIL ACTION - LAW THOMAS B. DIVVER and CAPITAL MEATS, INC., Defendant : JURY TRIAL DEMANDED PRAECIPE TO THE CUMBERLAND COUNTY PROTHONOTARY: Please reinstate the attached Complaint in reference to the above -captioned action and return to our office for service. Thank you. Date: 5/15/14 MARTSON LAW OFFICES By i/ Gorge .. Faller, Jr., I.D. Number 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff squire 41 3.6y -s=43- F:\FILES\Clients\3050 Donegal\3050 Current \3050.71 1 \3050.71 I aff2. wpd Revised: 5/23/14 0:26PM George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs OTTO GILROY & FALLER THE PRO HONDTA n,Y 2014MAY 27 AM 9:20 CUMBERLAND COUNTY PENNSYLVANIA CARLYN BUTZ, Plaintiff V. THOMAS B. DIVVER and CAPITAL MEATS, INC., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-1488 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE OF COMPLAINT COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND I hereby certify that a copy of the Complaint in the above captioned matter was mailed to Thomas B. Divver, Carroll County Detention Center, 100 N. Court Street, Westminster, MD 21157, by certified mail. Attached is the Post Office return receipt signed and dated May 20, 2014. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shelly Taylor, Notary Public Carlisle Boro, Cumberland County My Commission Expires Aug. 5, 2017 MEMBER, P=NUISYLVANIA ASSOCIATION OF NOTARIES Sworn to and subs ribed before me this 03 day of MARTSON LAW OFFICES By George B. Faller, Jr., ij'squire Attorney ID No. 4981 Ten East High Street Carlisle, PA 17013 (717) 243-3341 , 2014. • i Postal tigrafto CERTI IED (Domestic MAIL CifOCkttab Insurance 6O -/Ii G6r C -IP Coverage Provided) delivery dieiliiraltimaiDcancinalogomegpaecab OFFICIAL USE Postage Certified Fee Return Receipt Fee (Endorsement Required) • Restricted Delivery Fee (Endorsement Required) Total Postage & Fees Sent To ,CJV }.Crr2il Cot Sire as Afi no.; or PO Box No. I:, CIty, State, P+4 1Afp&mIr0-er . PO HS') �. C. zi LP:conI: •. SENDER: COMPLETE THIS SECTION ■ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. • Print your name and address on the reverse so that we can return the card to you. • Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ►kkr. `Ihtrma.l ox( 100 N. Cal S44red- 1P0vi \ ns ,t , 1) 5t) COMPLETE THIS SECTION ON DELIVERY -. A. Signatu X B. Received by (Printed Name) ❑ Agent ❑ Addressee C. Date of Deliv —�1 ry D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No 3. Se ice Type Certified Mail ❑ Registered ❑ Insured Mail ❑ Express Mail ❑ Return Receipt for Merchandise ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) ❑ Yes 2. Article Number (Transfer from service label) 7010 1060 0001 1047 5090 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CARLYN BUTZ, CASE NUMBER: 14-1488 Plaintiff ISSUE NUMBER: f[[Y?Y r V• PLEADING: THOMAS B. DIVVER and CAPITAL MEATS, INC., PRAECIPE FOR APPEARANCE ''_' Defendants CODE AND CLASSIFICATION: FILED ON BEHALF OF: CAPITAL MEATS, INC., Defendant. COUNSEL OF RECORD: E. RALPH GODFREY, ESQUIRE Pa. ID# 77052 CIPRIANI & WERNER, P.C. 1011 Mumma Road, Suite 201 Lemoyne, PA 17043 (717) 975-9600 �7 T�� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CARLYN BUTZ, Plaintiff v. THOMAS B. DIVVER and CAPITAL MEATS, INC., Defendants CIVIL DIVISION CASE NO: 14-1488 PRAECIPE FOR APPEARANCE TO: PROTHONOTARY OF CUMBERLAND COUNTY Please enter my appearance only on behalf of the Defendant, CAPITAL MEATS, INC., in the above -captioned matter. BY: Respectfully submitted, CIPRIANI & WERNER, P.C. E. ' • -PH G Counsel for the D A JURY TRIAL IS DEMANDED CAPITAL MEAT S IC. CERTIFICATE OF SERVICE That counsel for the Defendant, CAPITAL MEATS, INC., hereby certifies that a true and correct copy of its PRAECIPE FOR APPEARANCE has been served on all counsel of record and pro se parties by first class mail, postage pre -paid, according to the Pennsylvania Rules of Civil Procedure, on the / el -day of `Jv , 2014. George B. Faller, Jr., Esquire Martson, Deardorff, Williams & Otto 10 East High Street Carlisle, PA 17013 (Counsel for Plaintiff Thomas B. Divver Caral County Detention Center 100 North Court Street Westminster, MD 21157 (Defendant) BY: Respectfully submitted, CIPRIANI & WERNER, P.C. E. DFRE SQUIRE Counsel for the De d. t, CAPITAL ME IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CARLYN BUTZ, ) CASE NO: 14-1488 ) r r Plaintiff ) rri v. ) §(Zi THOMAS B. DIVVER and CAPITAL ) rcp MEATS, INC., Defendants ) ) ) STIPULATION TO DISMISS LANGUAGE FROM PLAINTIFF'S COMPLAINT It is hereby STIPULATED and AGREED upon, by and between Plaintiff, Carlyn Butz, and Defendant, Capital Meats, Inc., by and through their respective counsel, that any and all reference to "reckless" contained in Paragraphs 8 and 11 as well as anywhere else in tie Complaint are STRICKEN and DISMISSED. Furthermore, Plaintiff is not seeking an award of punitive damages. George B. ` . er, r., Esquire II Counsel fs e Plaintiff Date: E. Ralph Godfrey, Esqu Counsel for the Defenda Inc. /2"_e_//(.1Date:6 CERTIFICATE OF SERVICE I, the undersigned, hereby certify that a true and correct copy of the STIPULATION TO DISMISS LANGUAGE FROM PLAINTIFF'S COMPLAINT has been served on all counsel of record and pro se parties by first class mail, postage pre -paid, according to the Pennsylvania Rules of Civil Procedure, on the 9"1-' day of , 2014. George B. Faller, Jr., Esquire Martson, Deardorff, Williams & Otto 10 East High Street Carlisle, PA 17013 (Counsel for Plaint Thomas B. Dieser Caral County Detention Center 100 North Court Street Westmin>ter, MD 21157 (Defendant) BY: CIPRIANI & WERNER, P.C. E. RALPH GODF Counsel for the Defe t, Capita eats, Inc. F:\FILES\Clients\3050 Donegal\3050 Current \3050.71 1 \3050.71 I aff2. wpd Revised: 5/23/14 0:26PM George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs OTTO GILROY & FALLER THE PRO HONDTA n,Y 2014MAY 27 AM 9:20 CUMBERLAND COUNTY PENNSYLVANIA CARLYN BUTZ, Plaintiff V. THOMAS B. DIVVER and CAPITAL MEATS, INC., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-1488 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE OF COMPLAINT COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND I hereby certify that a copy of the Complaint in the above captioned matter was mailed to Thomas B. Divver, Carroll County Detention Center, 100 N. Court Street, Westminster, MD 21157, by certified mail. Attached is the Post Office return receipt signed and dated May 20, 2014. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shelly Taylor, Notary Public Carlisle Boro, Cumberland County My Commission Expires Aug. 5, 2017 MEMBER, P=NUISYLVANIA ASSOCIATION OF NOTARIES Sworn to and subs ribed before me this 03 day of MARTSON LAW OFFICES By George B. Faller, Jr., ij'squire Attorney ID No. 4981 Ten East High Street Carlisle, PA 17013 (717) 243-3341 , 2014. • i Postal tigrafto CERTI IED (Domestic MAIL CifOCkttab Insurance 6O -/Ii G6r C -IP Coverage Provided) delivery dieiliiraltimaiDcancinalogomegpaecab OFFICIAL USE Postage Certified Fee Return Receipt Fee (Endorsement Required) • Restricted Delivery Fee (Endorsement Required) Total Postage & Fees Sent To ,CJV }.Crr2il Cot Sire as Afi no.; or PO Box No. I:, CIty, State, P+4 1Afp&mIr0-er . PO HS') �. C. zi LP:conI: •. SENDER: COMPLETE THIS SECTION ■ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. • Print your name and address on the reverse so that we can return the card to you. • Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ►kkr. `Ihtrma.l ox( 100 N. Cal S44red- 1P0vi \ ns ,t , 1) 5t) COMPLETE THIS SECTION ON DELIVERY -. A. Signatu X B. Received by (Printed Name) ❑ Agent ❑ Addressee C. Date of Deliv —�1 ry D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No 3. Se ice Type Certified Mail ❑ Registered ❑ Insured Mail ❑ Express Mail ❑ Return Receipt for Merchandise ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) ❑ Yes 2. Article Number (Transfer from service label) 7010 1060 0001 1047 5090 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 F:\FILES\Clients\3050 Donegal\3050 Current Current\305071 I \3050.71 I . pra2.wpd/ajt Created: 7/10/03 10:28AM Revised: 8/19/14 752AM George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff -OFFICL CF THE HOTHONO TAIO 2314 AUG 19 AM 9: .14 CUMBERLAND COUNTY PENNSYLVANIA CARLYN BUTZ, Plaintiff v. THOMAS B. DIVVER and CAPITAL MEATS, INC., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-1488 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE TO THE CUMBERLAND COUNTY PROTHONOTARY: Please reinstate th 1•P6\ Complaint in reference to the above -captioned action and return to our office for service. Thank you. MARTSON LAW OFFICES By Date: 8/19/14 Geor B. Faller, Jr., I.D. Number 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff squire